CH175100 | Special reduction: Reviews and penalty appeals

A person may ask for a review of the penalty and special reduction may be considered as part of the review.

If it is considered likely that a submission to the Specialist Technical Team, see CH175000 may be required it would be appropriate to negotiate an extension to the review period at an early stage.

A person cannot appeal directly against our decision not to allow a special reduction, but they can appeal against the amount of the penalty we impose.

A tribunal may

• either affirm HMRC’s decision on special reduction (but possibly apply the same percentage reduction to a different starting point)

• or substitute their decision on special reduction for HMRC’s decision, but only if the tribunal considers that HMRC’s decision was flawed, see CH64600.